“Small changes within an ecosystem resulting in the loss of individuals and species can … result in adverse, irreversible and broad ranging effects.”

In a proposal that was missed by many in the excitement over the Province of BC’s announcement of banning all grizzly bear hunting, Environment Canada has drafted an order to amend the federal Species at Risk Act (SARA) to include grizzly bears as a species of ‘Special Concern’. You can read the formal announcement in the Canada Gazette Part I, Vol. 151, No. 50.

The objective of the proposed Order is to “help maintain Canada’s biodiversity and the health of Canadian ecosystems by preventing wildlife species from becoming extirpated or extinct from Canada and contribute to their recovery”(1).

This is another step in the right direction for Canada’s grizzlies that should, eventually, bring additional federal protection to its populations. While SARA has many limitations in terms of the protections it can offer grizzlies, we still support this listing as it will lead to federal management planning for grizzlies, which we think should focus on the most at-risk subpopulations that have recently been designated as critically endangered by the International Union on the Conservation of Nature (IUCN).

We also hope this designation as a species of special concern federally will act as another reason for jurisdictions such as BC, Alberta and the Yukon to finally draft and enact effective species at risk legislation, which could be a much more effective tool to address grizzly bear subpopulations’ needs in different areas of the country. (See Failure to Protect, Ecojustice 2012/2014 and The Last Place on Earth, Ecojustice 2008 for more on the need for provincial and territorial species at risk laws, as well as better use of SARA).

Comments on the proposed listing of grizzly bears are due by January 18. You can make submissions directly here, or via our friends at CPAWS and Coast to Cascades action page here. We’re sending in a letter as well, which can be viewed here or at the bottom of this post.

Grizzlies - especially their most vulnerable subpopulations - need protection before the cumulative threats facing them take too much of a toll and it's too late for the bears to recover.

What does Species of Special Concern mean?

“Species of special concern” means a species that, due to a combination of biological characteristics and identified threats, is at risk of becoming threatened or endangered. Listing a species as one of special concern means that the government must, within three years, create a management plan for the species and its habitat. The plan must include measures for the conservation of the species that the minister, in consultation with other relevant parties, landowners and governments, considers appropriate (see sections 65-72 of SARA).

Why have grizzlies had to wait so long to be recognized by SARA?

The Committee on the Status of Endangered Wildlife in Canada (COSEWIC) has recognized the grizzly bear as a Species of Special concern, in one way or another, since 1991. At that point, the Canada wide grizzly population was assessed in subpopulations “Northwestern” and “Prairie”; the Northwestern population was designated “of special concern” while the Prairie population was designated “extirpated” (locally extinct), and subsequently listed as such in SARA. (2)

When the federal Species At Risk Act came into force in 2004, COSEWIC undertook another assessment of Canadian grizzly bears, reaffirming the Northwestern population as “of special concern”. However, this Northwestern population never actually got listed as such under SARA.

COSEWIC’s recommendation for the Western population of the grizzly bear to be listed as of special concern was received by the Minister October 5, 2010,but the decision to put the species on the list has been repetitively extended for reasons we can only speculate about.

Many of the dozen other species of flora and fauna such as the American badger that are part of this draft order to amend SARA also have outdated status under the Act or have had their listing delayed. This order proposed by the current federal government seems to be a bit of housekeeping to finally make good on some of the many ‘extended consultation’ paths of species that have been assessed by COSEWIC.

COSEWIC’s most recent 2012 assessment confirms that the listing of grizzly as a species of special concern is due to its high sensitivity to human disturbance, declining populations and unsustainable mortality rates in parts of its range, naturally low reproductive rates and genetic fragmentation, and increasing pressures of resource extraction (3). If these threats are not addressed the species could quickly slip into a status of threatened or endangered.

It should be noted that in the 2012 assessment the subpopulations were reorganized, combining the Northwestern and Prairie populations into the single unit known as the Western population, and separating out the extinct Ungava population, which once covered northern Québec and Labrador but has not been documented since 1948 and is listed as Extirpated under Schedule 1 of SARA.

Can this SARA listing be used as jumping off point for provincial species at risk action, Indigenous Guardian initiative funding and salmon protection? That’s our hope - here’s our submission to the federal government in response to the proposed SARA amendment.

Grizzly Bear Foundation is the only Canadian charitable organization dedicated solely to the welfare of grizzly bears (Ursus arctos). We work collaboratively to support the conservation and preservation of grizzly bears through research and public education.

We are pleased to submit our comments expressing support for the proposal to list the grizzly bear (Western population) as a species of ‘special concern’ on Schedule 1 of the Species at Risk Act.

Grizzly bears need to be listed under SARA

Since the arrival of Europeans in North America, the grizzly bear’s range has suffered in proportion to the number of humans taking over the landscape. The current North American range of grizzly bears is a fraction of what it once was, with many of the still-sustainable populations occupying Canada, and much of the suitable grizzly bear habitat (current or potential) existing in Canada. (4, pages 3-6)

As Canadians who espouse to be stewards of wildlife and their habitat, we have a responsibility to ensure that this line of extirpation does not continue. Listing under Schedule 1 would be an important, concrete step toward preventing the loss of any more subpopulations of grizzly bears, preventing the species’ Canadian range from shrinking further, and ensuring a better future for the overall population as well as specific subpopulations.

Subpopulations need to be considered in developing a management plan

The purposes of SARA are to prevent wildlife species from becoming extirpated from Canada or extinct; to provide for recovery of wildlife species that are listed as extirpated, endangered or threatened as a result of human activity; and to manage species of special concern to prevent them from becoming endangered or threatened. The background to the current proposed Order also states that, “small changes within an ecosystem resulting in the loss of individuals and species can therefore result in adverse, irreversible and broad-ranging effects.”(5, page 4765) While the Order is based on the recommendation of COSEWIC and refers to the Canadian grizzly bear population as a whole, it is within this context that we urge the federal government to consider subpopulations of grizzly bears as well, as those ecosystems and the individuals and species within them are linked to the health and trajectory of the Western population and species as a whole.

Canada’s most at-risk grizzly bear subpopulations face urgent issues like habitat loss and fragmentation, genetic and demographic isolation, food insecurity, and human-bear conflicts often resulting in death. In British Columbia, several subpopulations are provincially recognized as threatened, and three were recently assessed as Critically Endangered, one as Endangered and one as Vulnerable by the International Union for the Conservation of Nature (IUCN)(5).

We encourage the federal government to study and take action in relation to the subpopulations of grizzlies that are at highest risk of decline and potential extirpation, as identified by IUCN. We feel that consideration of subpopulations is especially important following the ‘consolidation’ of the former Prairie and Northwestern populations into the newly defined ‘Western’ population; while we understand the rationale for this, we are concerned it decreases the ability of the federal government, via SARA, to take a nuanced approach to address the needs of vulnerable, threatened and critically endangered subpopulations.

We urge the federal government to act quickly to develop and implement a management plan that prioritizes conservation and recovery measures for those grizzly subpopulations where the threat of extirpation and range contraction is the greatest.

Indigenous Guardian programming should be mobilized to assist with grizzly bear management

Critical factors in the success of any conservation efforts include respecting local and traditional knowledge as well as effective implementation and enforcement on the ground. Both formal and informal Indigenous guardian programs have been successful at educating (including with Indigenous knowledge and laws), mobilizing and employing (where there is sufficient funding) guardians to steward, monitor and guard local ‘resources’. This is especially notable in BC in relation to grizzly bear studies and conservation.

As one strategy to ensure local coordination with the proposed designation of grizzly bears as special concern, and the related management planning that will occur, we recommend close communication between the Canadian Wildlife Service and Parks Canada, who we understand is now responsible for the Indigenous Guardian initiative federal funding. We feel that the listing of grizzly bears under SARA and the federal funding (in budget 2017) to develop a National Indigenous Guardian Network provides a promising opportunity for incorporating Indigenous knowledge into management planning and integrating Indigenous governance into monitoring and enforcement.

Enhancing SARA’s ability to protect grizzlies by advocating for provincial and territorial legislation

The statement by the Department of Environment in the Gazette Part I acknowledges that, “although the responsibility for the conservation of wildlife in Canada is shared among jurisdictions, the Department of the Environment plays a leadership role as regulator in order to prevent species from becoming extinct at the global scale or extirpated from Canada.”(6, page 4766)

Creation of a management plan within three years of the listing of grizzly bears on Schedule 1 will require consultation with, among others, the relevant provincial, territorial and First Nations governments. We believe this would be an appropriate and strategic opportunity for the federal government to, in their acknowledged leadership role, call for the creation of provincial and territorial species at risk legislation. Current grizzly bear habitat largely overlaps with the territories and few provinces that either have no (BC, Alberta, Yukon, Nunavut) or very underutilized (NWT) legislation for species at risk (7). Given the limited utility of SARA’s protections and its ability to protect critical habitat, making real progress on preventing the further decline of the grizzly bear and its habitat across Canada will require significant contributions from other levels of government, and they would certainly benefit from legal tools to use in that work.

Salmon conservation

Grizzly bear conservation, the recovery of subpopulations and the prevention of threatened or extirpated subpopulations will depend heavily on protection of food sources. Throughout most of British Columbia, grizzly bear health is strongly tied to the health of our salmon populations. For one example, see a recently published study showing the correlation of grizzly bears and salmon nutrients throughout the province of BC (8). We recommend that efforts to conserve the grizzly bear, including the development of a grizzly bear management plan, include careful consideration of how the Western grizzly bear population as well as its subpopulations are tied to the health of salmon runs throughout British Columbia.

We also recommend that the Canadian Wildlife Service liaise with DFO and those implementing the Wild Salmon Policy to determine a wildlife allocation that includes nutritional needs of grizzly bears, as it is a keystone species in the predator-scavenger complex that uses and distributes marine nutrients (9, pages 17-19).

Public support for grizzly bear conservation

Since our incorporation in 2016, we have received very strong support from citizens for our mission to conserve and ensure the long term welfare of grizzly bears. Grizzly bear conservation in BC in particular has been an active issue in recent years. Several recent professionally conducted public opinion polls (10) and the provincial government’s own 2017 consultation efforts (11) have indicated overwhelming support of banning grizzly bear hunting, an indication that this species holds a special place in the minds and hearts of many Canadians. Indeed, many observe that the grizzly bear is a Canadian icon, inextricably linked to our identity and pride, as well as to our Canadian and Indigenous cultures and to the health of our communities (12, pages 4-10). This adds yet another rationale for the federal government to act on a mandate to play a more active role in safeguarding and stewarding this sensitive and important indicator species.

Thank you for your consideration of our feedback on the Order to Amend Schedule 1 to the Species at Risk Act. Please contact us at your convenience with any questions or concerns.

Yours sincerely,

GRIZZLY BEAR FOUNDATIONRachel S Forbes, LL.BExecutive Director

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Photo: Jim & Doria Moodie

1 Response

Masry Andrews

February 22, 2018

I think all lands outside urban and agricultural areas should be turned over to First Nations management. Hopefully most have yet to be co-opted by industry.

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